In banking and finance, transnationality permeates the day-to-day professional life and makes the dedicated lawyer an internationalist by necessity. There are good reasons for this: the intangible nature of services, the desire of operators even regulated to conquer foreign markets; sometimes because of the extraterritorial spread of local policies relating to the person of the operators or the products marketed. Although it does not always have a good reputation, private international law, with its promise of a widely understood conflict-oflaws discipline, is making inroads into the legal practice of this specialised and globalised sector.

For a young academic, it was an ambitious undertaking to systematically combine private international law with the law of financial markets and instruments. All the more so since, as Mr Augustin Gridel's methodological commitment attests from the introduction to his thesis, any good conflict-oflaws solution is developed by contemplating the domestic legal and regulatory material potentially applicable to cross-border relations. The relevant domestic law is widely publicised and, in Europe at least, consists of two equal layers, one national, the other European.

One therefore encounters the difficulty inherent in these matters, which are steeped in administrative regulation: the international applicability of public law plays a driving role, although the theory is not guaranteed, since it constitutes the dark side of the conflict-of-laws’ historical development.